SOUTHPAC STRENGTH PRIVACY POLICY

General

Southpac Strength Pty Ltd ACN 676 591 156 and its related entities (referred to in this document as ‘we’, ‘us’ or ‘our’) recognises that your privacy is important, and we are committed to protecting the personal information we collect from you. The Privacy Act 1988 (Cth) (‘Privacy Act’), and the Australian Privacy Principles (‘APP’) govern the way in which we must manage your personal information and this policy sets out how we collect, use, disclose and otherwise manage personal information about you.

Collection

Types of Information Collected

We may collect and hold personal information about you, that is, information that can identify you, and is relevant to providing you with the services you are seeking.

This can include:

• your name;

• date of birth;

• contact details (including address, email address, phone number);

• financial information (such as credit card or bank account numbers);

• limited health information (with your consent);

• any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information; and

• information you provide to us through customer surveys and information about how you use our products and services.

The above noted types of information collected is not an exhaustive list. We may need to collect additional information about you from time to time to provide products or services to you. In addition, when you apply for a job or position with us we may collect certain information from you (including, in addition to the above noted details, working history and relevant records checks) from any recruitment consultant, previous employers and others who may be able to provide information to us regarding your suitability for employment.

This Privacy Policy does not apply to acts and practices in relation to employee records of our current and former employees, which are exempt from the Privacy Act in Australia. You might also need to provide us with personal information about other individuals (e.g. emergency contacts, carers, etc.). If so, we rely on you to inform those individuals that you are providing their personal information to us and to advise them about this policy.

Purpose of collection

The type of personal information that we collect and hold about you depends on your interaction with us. Generally, we will collect, use and hold your personal information to:

• enable you to access and use our services and app (whether that means becoming a member, booking a class or session or joining a challenge);

• operate, protect, improve and optimise our services and app, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;

• send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;

• send membership offers, promotions or discounts; • send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;

• administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;

• comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties;

• consider your employment application;

• answer your questions, provide you with information or advice or consider and respond to requests or complaints made by you;

• provide other products or services to you or someone else you know;

• issue tax invoices for the products or services we may provide to you from time to time.

Method of collection

Personal information will generally be collected directly from you through:

• the use of any of our standard forms (such as when you complete a membership application form or registration form, enter into an agreement with us, contact us with a query or request or submit your details through our website, app or by email);

• conversations with our reception, trainers or other staff (by phone, in person or electronically); or

• your use of our website (see below under heading ‘Internet Users’) or customer service lines. We may also collect information other than directly from you, for example from:

• third parties such as our related entities, business partners, or your representatives;

• publicly available sources of information;

• our records of how you use our services; and

• the third parties we list in the section of this policy with the heading ‘Use and disclosure’.

If you choose not to provide certain information about you, we may not be able to provide you with the products or services you require, or the level of service on which we pride ourselves. If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the products or services you, or they, are seeking.

Internet users

If you access our website, app or social media platforms we may collect additional personal information about you in the form of your IP address and domain name. Our website(s) uses cookies. The main purpose of cookies is to identify users and to prepare customised web pages for them. Cookies do not identify you personally, but they may link back to a database record about you. We use cookies to monitor usage of our website(s) and to create a personal record of when you visit our website(s) and what pages you view so that we may serve you more effectively. Our website(s) may contain links to other websites. We are not responsible for the privacy practices of linked websites and linked websites are not subject to our privacy policies and procedures.

Use and disclosure

Generally, we only use or disclose personal information about you for the purposes for which it was collected (as set out above) or for purposes which are directly related to one or more of our functions and activities. This means that we may disclose personal information about you for purposes required for the administration and operation of our business, including (but not limited to):

• disclosing information to our trainers and other employees;

• administering billing (including administration of insurance and other third-party payment arrangements) and debt recovery;

• managing, monitoring, planning and evaluating our services;

• safety and quality assurance and improvement activities;

• training of staff;

• testing and maintenance of information technology systems;

• product and service development, quality control and research to improve the way we provide products and services to you;

• to seek your feedback in relation to customer satisfaction and our relationship with you and perform research and statistical analysis using such feedback;

• risk management and management of legal liabilities and claims (for example, liaising with our insurers and legal representatives);

• obtaining advice from consultants and professional advisers;

• responding to subpoenas or other legal orders and obligations; and

• to comply with laws or regulations or to comply with any directions given by regulators or authorities (including with respect to quarantine, public health and notifiable diseases).

We may also disclose personal information about you to:

• appropriate authorities as legally required;

• third party product or service providers, who assist us in operating our business (including to assist us in providing you with the products and or services that you have requested or have expressed an interest in), and these service providers may not be required to comply with our privacy policy; and

• our related entities and other organisations with whom we have affiliations so that those organisations may provide you with information about services and various promotions.

We are unlikely to disclose your personal information to overseas recipients. In the unlikely event that we are required to disclose your personal information to an overseas recipient, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your personal information, unless we have your consent to disclosure your personal information without taking such steps, or an exception under the Australian Privacy Principles applies.

How we use your information for Direct Marketing

We may also use your information so that we, our related entities, and other business partners can promote and market products, services and special offers that we think will be of interest to you (which may include products, services and offers provided by a third party). This marketing may be carried out in a variety of ways (including by email, SMS/MMS, or social media) and may continue after you cease acquiring any products or services from us until you opt-out. We acknowledge and respect our customers’ choice to ‘opt-out’ of direct marketing communication activities undertaken by us. You may opt out of direct marketing communications at any time by emailing sup@southpacstrength.com.au.

How we hold your personal information

The security of your personal information is of paramount importance to us. We store your personal information in different ways, including in paper and in electronic form. Any bank or credit card details you provide and that we store will be encrypted, and any tax invoices we issue to you will not display your full bank or credit card details, for your added protection. The security of your personal information is important to us. We take all reasonable measures to ensure that your personal information is stored safely to protect it from misuse, loss, unauthorised access, modification or disclosure. If we no longer need your personal information for the purposes for which it was collected or for purposes which are directly related to one or more of our functions and activities, we will take reasonable steps to securely destroy it or permanently remove all identifying features from that information. This obligation is subject to any legal requirement or Court order to retain the information.

How you can access your personal information

You may access the personal information we hold about you, upon making a written request. We take all reasonable steps to ensure that the personal information we hold, use and disclose is accurate, complete and up to date. If, upon receiving access to your personal information or at any other time, you believe the personal information we hold about you is inaccurate, incomplete or out of date, please notify us immediately. We will take reasonable steps to correct the information so that it is accurate, complete and up to date. If you wish to access any of your personal information that we hold or would like to correct any errors in that information, please contact us by email at sup@southpacstrength.com.au, so that we can consider and respond to your request. We may apply an administrative charge for providing access to your personal information in response to a request.

Complaints

You may use the contact details below to notify us of any privacy complaint you have against us, including if you think that we have failed to comply with the APP or any binding APP code that has been registered under the Privacy Act. We are committed to acknowledging your complaint in a prompt manner and will give you an estimated timeframe for when we will respond to your complaint. If you are unhappy with the way that we handle your complaint you may make your complaint to the Office of the Australian Information Commissioner.

Contact

If you have any queries or concerns about our privacy policy or the way we handle your personal information, please contact Management by email at: sup@southpacstrength.com.au.

Changes to our privacy and information handling practices

This privacy policy is subject to change at any time. Please check our privacy policy on our website regularly for any changes.

More information

For more information about privacy in general, you can visit the Office of the Australian Information Commissioner website at http://www.oaic.gov.au/

Timetable